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Inheritance tax: the nuances of ‘interest in possession’
Before the sudden reforms of the inheritance tax rules in March 2006, there was a fundamental distinction between life-i...
Beneficial loans: the importance of getting your timing right
I can remember the first time that I came across an assessment in relation to a loan to a participator....
A yellow card for IR35? What the Lineker case means for HMRC
Ever since the infamous announcement following the 1999 Budget, the so-called IR35 legislation has rarely been outside t...
Fish and chip shops: a flawed HMRC investigation to cash-only businesses
In the more than 30 years that I have been in the tax profession, certain types of business have been seen as likely can...
High income child benefit charge: a number of problems...
© Getty images/iStockphoto The high income child benefit charge has always been a controversial measure, ever since it...
Enterprise zone allowances: the basis of a ‘golden contract’
In my article ‘A golden contract’ in the February 2020 issue of Tax Adviser, I discussed the Upper Tribunal’s decision i...
Cumming-Bruce v HMRC: Enquiries into capital loss claims
Lying at the heart of the Self Assessment system is HMRC’s power of enquiry.
The availability of main residence exemption when a house is rebuilt
Although nothing can be taken for granted, there is a general assumption that no UK politician would seek to extend capi...
Quayviews: a company penalised for submitting its RTI returns early
I suspect that few readers will disagree with the proposition that, as a matter of principle, HMRC should have the power...